Acquisitions, Internal Revenue Code (IRC), Startups

Section 280G Unpacked: Pitfalls and Planning for Tech Startups

Lowenstein Sandler LLP on 6/7/2025

In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein’s Emerging Companies & Venture Capital practice group, about the complexities and challenges of...more

UK Founder Series: Flip Back from the U.S. – Key U.S. Tax Considerations

Orrick, Herrington & Sutcliffe LLP on 2/3/2025

Orrick's UK Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of...more

Employees’ Perspective on Source and Use for Series Financings and Acquisitions

Mintz - Employment Viewpoints on 1/27/2023

A primary goal of many, if not all, founders of start-ups and similar early-stage companies is to grow the company in a way that makes it an attractive target for outside investment and/or acquisition. For many companies,...more

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

Proskauer - Tax Talks on 9/23/2019

On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under...more

Proposed Section 382 Regulations Would Eliminate Section 338 Approach of Notice 2003-65

A&O Shearman on 9/19/2019

On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing certain previously...more

IRS Proposes Regulations That Would Limit Utilization of NOLs After Acquisitions and Other Ownership Changes

Wilson Sonsini Goodrich & Rosati on 9/19/2019

On September 9, 2019, the U.S. Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (the Proposed Regulations) that, if finalized, would significantly change the way corporations...more

Favorable Net Operating Loss Utilization Rules Could be Eliminated

Jones Day on 9/18/2019

Proposed regulations, if adopted, would impose substantial restrictions in many cases on a corporation's use of existing net operating losses and similar tax attributes after a substantial change in ownership. On September...more

Acquisitions › Internal Revenue Code (IRC) › Startups